4 Revision History Version Number Date Reason for Change /19/12 General Updates: Updates electronic specification document title from Bank Secrecy Act Designation of Exempt Person (FinCEN Form 110) Electronic Filing Requirements (see new title on cover page) and replaces BSA DOEP with FinCEN DOEP throughout the document. Replaces all references to filing organization with filing institution throughout the document. Acknowledgement File Format Updates the acknowledgement file format to include User values from incoming records. FinCEN DOEP Replaces the reference to the FinCEN DOEP as a form with throughout the document. Updates to File Organization: Filer Information (2A) Record Replaces filing organization with filing institution in the first sentence. Updates to Record Layout: Transmitter ZIP/Postal Code (as well as Items 23/11) Updates the Description and Remarks to include or four nines in the following statement: A nine-digit ZIP Code cannot end with four zeros or four nines. Transmitter Country Updates the Description and Remarks by adding the sentence See General Instructions 5 in Attachment C for information about the country codes to be entered. Coverage Beginning Date/Coverage Ending Date Updates the Description and Remarks by replacing original exemption with Effective Date of Exemption in the first sentence for each field. Effective Date of Exemption (Item 2) Updates the Description and Remarks by replacing following day s date after the date of the last transaction to be exempted with date of the day following the date of the last exempted transaction in the last sentence. Exempt person is entity Updates the Description and Remarks by replacing Enter X if the exempt person is an entity with Enter X if the exempt person is an entity and space fill the First Name, Middle Name, and Name Suffix fields. Middle Name/Name Suffix (Item 5) iii

5 Version Number Date Reason for Change Updates the Description and Remarks by replacing Space-fill if no entry with Space-fill if no entry or if Exempt person is entity contains X. address (Item 14) and Phone Number (Item 15) Updates the Name by removing (If available) for clarification purposes. Items 26/27/29 Updates the Description and Remarks by removing Space-fill if no entry. BSA Identifier/Document Control Number Updates the Name and Description and Remarks by replacing BSAI with BSA ID. Updates to Attachment A Error Code List Errors Codes Adds the error code F24 Number of forms ed on the batch form does not match the computed count of the forms found in the file to the list of error codes. Attachment B Error Correction Instructions Error Categories Replaces the statement fatal errors that result with format errors that may result in the first sentence of the section. Attachment C Electronic Filing Instruction General Instructions (7. Name Editing Instructions) Updates 7. Name Editing Instructions to match the instructions in the FinCEN SAR and FinCEN CTR. Item Instructions (Item 18 EIN) Updates Item 18 EIN instructions to Enter the bank s Employer Identification Number (EIN). Item Instructions (Item 25 Affiliated banks Adds some or in the following sentence: A parent bank holding company or one of its bank subsidiaries may make the designation of exempt person on behalf of some or all bank subsidiaries of the holding company so long as the designation lists each bank subsidiary that will treat the customer as an exempt person. Secure Data Transfer Mode Users Updates the instructions to include a section describing the naming convention information related to SDTM/System to System filers. iv

6 Version Number Date Reason for Change /27/14 Attachment C Electronic Filing Instructions General Instructions (5. Addresses): Removed Note: The ISO country list includes entries for all U.S. territories. Do not use these U.S. territory entries, which match the U.S. Postal Service abbreviations required in state fields, in any country field. Added Note: The ISO country list contains entries for all U.S. territories, including the United States Minor Outlying Islands. Do not use these U.S. territory entries, which may match the U.S. Postal Service abbreviations required in state fields, in any country field /01/2015 Updates to Attachment C Electronic Filing Instructions General Instructions (5. Addresses): Removed Note: The ISO country list contains entries for all U.S. territories, including the United States Minor Outlying Islands. Do not use these U.S. territory entries, which may match the U.S. Postal Service abbreviations required in state fields, in any country field. This change was made as the discrete (online) s were updated to include the following entries in Country fields: American Samoa, (AS) Guam, (GU) Marshall Islands (the), (MH) Micronesia (the Federated States of), (FM) Northern Mariana Islands (the), (MP) Palau, (PW) Puerto Rico, (PR) Virgin Islands (U.S.), (VI) These values can now be used in Country fields to adhere to the ISO standard. v

7 Purpose The purpose of this document is to provide the requirements and conditions for electronically filing the Bank Secrecy Act Designation of Exempt Person (DOEP) (FinCEN Form 110). Electronic filing of this will be through the BSA E Filing System operated by the Financial Crimes Enforcement Network (FinCEN). For more information on the BSA E Filing System and to register, please go to This document should be used in conjunction with the General Specifications for Electronic Filing of Bank Secrecy Act (BSA) Reports (General Specifications) available at It is recommended that you refer to the General Specifications first, and then the specific information contained in this document. If the General Specifications conflict with any specific requirement found in this document, the specific requirement should be followed. Additional instructions concerning the data to be entered in the electronic file are found in Attachment C Electronic Filing Instructions. Electronic Filing The BSA E Filing System Batch File Testing Procedures are detailed in a separate document that can be accessed on the BSA E Filing System web site at under Quick Links. For purposes of this document, the filer is the organization responsible for filing the FinCEN Form 110 (DOEP) and the transmitter is the organization responsible for preparing the electronic files. The filer and transmitter may be the same or different organizations. Filers are required to retain a copy of the DOEP data and all original supporting documentation or business record equivalent for five years from the date of the. All supporting documentation must be made available to appropriate authorities upon request. 1

8 File Organization The following data controls must be followed or the DOEP electronic file will be rejected. The data records must be in the following sequence: Transmitter (1A) Record Required There can only be one of these record types and it must be the first record on the file. Filer Information (2A) Record Required There must be one of these record types for each filing institution on the file. This record type immediately precedes all records related to the filer. Affiliated Bank Information (2B) Record One or more of these record types may follow a 2A Record when the designation is being made for one or more affiliated banks. Filers are permitted to associate up to 99 2B records for a single exemption. Multiple 2B records must be grouped together prior to the associated Exempt Person Information (3A) Record(s). Exempt Person Information (3A) Record Required There can only be one of these record types for each exempt person ed on the file. Filers are permitted to associate multiple 3A records with a single 2B record or a set of 2B records assuming the affiliated bank(s) is(are) the same for all associated 3A records that follow. Filer Information Summary (9B) Record Required There must be one of these record types for each 2A record ed on the file. File Summary (9Z) Record Required There must be one of these record types on the file and it must be the last record. 2

9 Record Layouts Transmitter (1A) Record Required The first record on each file must be the Transmitter (1A) Record, which will contain information identifying the batch file transmitter (person or organization handling the data accumulation and formatting). There will be only one transmitter record on each electronic file. All data elements for this record are required. Position(s) Name Length Description and Remarks 1-2 Record Type 2 REQUIRED. Enter 1A Transmitter Name 150 REQUIRED. Enter the full name of the individual or organization that is transmitting the exemptions in this file. Left justify and space-fill the entry Transmitter Address 100 REQUIRED. Enter the street address of the transmitter. Left justify and space-fill the entry Transmitter City 50 REQUIRED. Enter the city of the transmitter. Left justify and space-fill the entry Transmitter State 3 REQUIRED. Enter the state code of the transmitter if the Transmitter Country is CA, MX, or US. Space-fill if Transmitter Country contains a country code other than CA, MX, or US Transmitter ZIP/Postal Code 9 REQUIRED. Enter the ZIP Code or foreign postal code of the transmitter. Do not include punctuation or formatting such as hyphens, periods, and spaces within the entry. An entry must be five or nine digits if Transmitter Country is US. A ninedigit entry cannot end with four zeros or four nines if Transmitter Country is US. Left justify and space-fill this entry if less than nine digits Transmitter Country 2 REQUIRED. Enter the country code of the transmitter. See General Instruction 5 in Attachment C for information about the country codes to be entered Transmitter Telephone Number 16 REQUIRED. Enter the telephone number of the transmitter. Enter as a single number string without formatting and punctuation such as spaces, hyphens, or parenthesis. Left justify and space-fill the entry. 3

10 Position(s) Name Length Description and Remarks Transmitter Contact Name 150 REQUIRED. Enter the name of an official contact for the transmitter. Left justify and space-fill the entry Transmitter Taxpayer Identification Number (TIN) Coverage Beginning Date Coverage Ending Date Transmitter Control Code (TCC) Batch Sequence Number (BSN) 25 REQUIRED. Enter the U.S. or foreign Taxpayer Identification Number (TIN) assigned to the transmitter. Do not enter hyphens, slashes, or invalid entries such as all nines, all zeros, or Left justify and space-fill the entry. 8 REQUIRED. This will be the date of the earliest Effective Date of Exemption on the file. Enter as a numeric 8-position entry in the format MMDDCCYY where MM = Month, DD = Day, CC = Century, and YY = Year. 8 REQUIRED. This will be the date of the latest Effective Date of Exemption on the file. Enter as a numeric 8-position entry in the format MMDDCCYY where MM = Month, DD = Day, CC = Century, and YY = Year. 8 REQUIRED. Enter the assigned 8-character Transmitter Control Code (TCC). Do not enter a TCC assigned for testing purposes. 3 Space-fill this field, which is reserved for BSA E-Filing use Filler 502 Space-filled Format Indicator 4 Space-fill this field, which is reserved for BSA E-Filing use User 10 Use this field for any descriptive information you may require; Space-fill if no entry. 4

11 Filer Information (2A) Record Required This record identifies information regarding the filing institution that is responsible for ing designation of exempt persons. The number of 2A records depends on the number of different filing institutions included on the file. The 2A record item numbers refer to Attachment C Electronic Filing Instructions Part III Filer Information, Items Position(s) Name Length Description and Remarks 1-2 Record Type 2 REQUIRED. Enter 2A Name of bank (Item 17) 150 REQUIRED. Enter the full legal name of the filing institution. Left justify and space-fill the entry EIN (Item 18) 25 REQUIRED. Enter the Employer Identification Number (EIN) of the filing institution. The EIN must be a valid nine-digit entry with no formatting such as hyphens, slashes, and alpha characters, or invalid entries such as all nines, all zeros, and Left justify and space-fill the entry RSSD (Item 19) 20 Enter the Research Statistics Supervision Discount (RSSD) number of the filing institution. Left justify and space-fill the entry. Space-fill if no entry Address (Item 20) 100 REQUIRED. Enter the permanent street address of the filing institution. Left justify and space-fill the entry City (Item 21) 50 REQUIRED. Enter the full name of the city of the filing institution. Left justify and space-fill the entry State (Item 22) 3 REQUIRED. Enter the appropriate state/territory code of the filing institution. Left justify and space-fill the entry. Use only the authorized U.S. Postal Service state, territory, or military address abbreviations found at ZIP Code (Item 23) 9 REQUIRED. Enter the ZIP Code of the filing institution. ZIP Codes must be five or nine digits in length and entered without formatting or special characters such as spaces or hyphens. A five-digit ZIP Code must be followed by four spaces. A ninedigit ZIP Code cannot end with four zeros or four nines. Left justify and space-fill the entry. 5

13 Affiliated Bank Information (2B) Record This record identifies information regarding the bank subsidiary that will be treating the customer as an exempt person. The number of 2B records depends on the number of different affiliated banks associated with each filing institution on the file. Filers are permitted to associate up to 99 2B records for a single exempt person. Multiple 2B records must be grouped together prior to the associated Exempt Person Information (3A) Record(s). The 2B record item numbers refer to Attachment C Electronic Filing Instructions Part III Filer Information Items Position(s) Name Length Description and Remarks 1-2 Record Type 2 REQUIRED. Enter 2B Name of bank (Item 17) 150 REQUIRED. Enter the full legal name of the affiliated bank. Left justify and space-fill the entry EIN (Item 18) 25 REQUIRED. Enter the Employer Identification Number (EIN) of the affiliated bank. The EIN must be a valid nine-digit entry with no formatting such as hyphens, slashes, and alpha characters, or invalid entries such as all nines, all zeros, and Left justify and space-fill the entry RSSD (Item 19) 20 Enter the Research Statistics Supervision Discount (RSSD) number of the affiliated bank. Left justify and space-fill the entry. Space-fill if no entry Address (Item 20) 100 REQUIRED. Enter the permanent street address of the affiliated bank. Left justify and space-fill the entry City (Item 21) 50 REQUIRED. Enter the full name of the city of the affiliated bank. Left justify and space-fill the entry State (Item 22) 3 REQUIRED. Enter the appropriate state/territory code of the affiliated bank. Left justify and space-fill the entry. Use only the authorized U.S. Postal Service state, territory, or military address abbreviations found at ZIP Code (Item 23) 9 REQUIRED. Enter the ZIP Code of the affiliated bank. ZIP Codes must be five or nine digits in length and entered without formatting or special characters such as spaces or hyphens. A five-digit ZIP Code must be followed by four spaces. A ninedigit ZIP Code cannot end with four zeros or four nines. Left justify and space-fill the entry. 7

15 Exempt Person Information (3A) Record Required This record identifies information regarding the exempt person and the DOEP filing. The number of 3A records depends on the number of different exempt persons included on the file. The 3A record item numbers refer to Attachment C - Electronic Filing Instructions Item 1-2, Part II Items 3-16, and Part IV Items Position(s) Name Length Description and Remarks 1-2 Record Type 2 REQUIRED. Enter 3A. 3-7 Sequence Number 5 REQUIRED. Enter a sequential number starting with and increment by 1 for each Exempt person Information (3A) Record. 8 Filing type (Item 1) 1 REQUIRED. Enter the appropriate code to record the type of filing. Code Description A Initial designation B Exemption amended C Exemption revoked 9-16 Effective Date of Exemption (Item 2) Individual's last name, or entity's legal name of the exempt person (Item 3) 167 Exempt person is entity 8 REQUIRED. Enter the effective date of exemption as a numeric 8-position entry in the format MMDDCCYY where MM = Month, DD = Day, CC = Century, and YY = Year. If Filing type is A Initial designation, enter the date of the first transaction to be exempted. If Filing type is B Exemption amended and the effective date of the exemption is not being amended, the date entered should be the same as the exemption date ed on the initial designation, or if the effective date of the exemption is being amended, enter the date of the first transaction to be exempted. If Filing type is C Exemption revoked, enter the date of the day following the date of the last exempted transaction. 150 REQUIRED. Enter the legal name (if entity) or last name (if individual) of the exempt person. If the exempt person is a sole proprietorship, enter the last name of the proprietor in this field. Enter the remainder of the proprietor s name in First Name, Middle Name, and Name Suffix. If the sole proprietorship has a name separate from the proprietor s name, enter that name in Alternate Name. 1 Enter X if the exempt person is an entity and space fill the First Name, Middle Name, and Name Suffix fields. Spacefill if no entry. 9

16 Position(s) Name Length Description and Remarks First Name (Item 4) 35 REQUIRED (conditional). If the exempt person is an individual, enter his/her first name. Left justify and space-fill the entry. Space-fill if Exempt person is entity contains X Middle Name (Item 5) 35 Enter the middle name or middle initial of the exempt person. Left justify and space-fill the entry. Space-fill if no entry or if Exempt person is entity contains X Name Suffix (Item 5) 35 Enter the name suffix such as JR, SR, III, etc. of the exempt person. Left justify and space-fill the entry. Space-fill if no entry or if Exempt person is entity contains X Alternate Name (Item 6) Occupation or type of business (Item 7) NAICS Code (Item 7a) 150 Enter the alternate name of the exempt person (e.g. AKA - individual or DBA - entity). Do not include the acronyms AKA or DBA with the alternate name. Left justify and space-fill the entry. Space-fill if no entry. 30 Enter the exempt person s occupation or type of business. Left justify and space-fill the entry. Space-fill if no entry. 6 Enter the NAICS Code associated with the exempt person s occupation or type of business. Access the NAICS Code list from the BSA E-Filing Web Site Left justify and space-fill this entry. Space-fill if no entry Address (Item 8) 100 REQUIRED. Enter the permanent address of the exempt person s business location. For exempt persons doing business at more than one physical location, enter the local headquarters address or local address of the exempt person. For a sole proprietorship, enter the business address of the sole proprietorship rather than the home address of the sole proprietor, unless they are the same. Left justify and space-fill the entry City (Item 9) 50 REQUIRED. Enter the full name of the city of the exempt person s business location. Left justify and space-fill the entry State (Item 10) 3 REQUIRED. Enter the state code of the exempt person s business location. Left justify and space-fill the entry. Use only the authorized U.S. Postal Service state, territory, or military address abbreviations found at 10

17 Position(s) Name Length Description and Remarks ZIP Code (Item 11) 9 REQUIRED. Enter the ZIP Code of the exempt person s business location. ZIP Codes must be five or nine digits in length and entered without formatting or special characters such as spaces or hyphens. A five-digit code must be followed by four spaces. A nine-digit code cannot end with four zeros or four nines. Left justify and space-fill this entry TIN (Item 12) 25 REQUIRED. Enter the exempt person s Taxpayer Identification Number (TIN). The TIN must be a valid nine-digit entry with no formatting such as hyphens, slashes, alpha characters, or invalid entries such as all nines, all zeros, or Left justify and space-fill the entry. 646 TIN type (Item 13) 1 REQUIRED. Enter the appropriate code to record the exempt person s TIN type. Code Description A EIN B SSN/ITIN address (Item 14) Phone Number (Item 15) Extension (if any) (Item 15a) 769 Type of exempt person (Item 16) 100 Enter the exempt person s address. Left justify and spacefill the entry. Space-fill if no entry. 16 Enter the telephone number of the exempt person. The telephone number must be a total of 10 digits in length, beginning with the exempt person s 3 digit area code followed by a 7 digit telephone number. Enter as a single number string without formatting and punctuation such as spaces, hyphens, or parenthesis. Left justify and space-fill the entry. Space-fill if no entry. 6 Enter the exempt person s telephone extension. Enter as a single number string without formatting and punctuation such as spaces, hyphens, or parenthesis. Left justify and space-fill the entry. Space-fill if no entry. 1 REQUIRED. Enter the appropriate code to record the type of exempt person. Code Description A Listed company B Listed company subsidiary C Eligible non-listed business D Payroll customer Print Name (Item 26) 150 Enter the name of the bank official who authorized this exemption. Left justify and space-fill the entry. 11

18 Position(s) Name Length Description and Remarks Title (Item 27) 35 Enter the title of the bank official who authorized this exemption. Left justify and space-fill the entry Phone Number (Item 29) Phone Number Ext. (Item 29a) Date of signature (Item 30) BSA Identifier (BSA ID)/ Document Control Number (DCN) 16 Enter the telephone number of the bank official identified as the authorizer of this. The telephone number must be a total of 10 digits in length, beginning with the exempt person s 3 digit area code followed by a 7 digit telephone number. Enter as a single number string without formatting and punctuation such as spaces, hyphens, or parenthesis. Left justify and space-fill the entry. 6 Enter the telephone extension of the bank official identified as the authorizer of this. Enter as a single number string without formatting and punctuation such as spaces, hyphens, or parenthesis. Left justify and space-fill the entry. Space-fill if no entry. 8 Enter the date of signature (i.e. authorization to submit) as a numeric 8-position field in the format MMDDCCYY where MM = month, DD = day, CC = Century, and YY = year. Space-fill if no entry. 14 REQUIRED (conditional). If Filing Type is B Exemption amended or C Exemption revoked, enter the BSA ID/DCN previously assigned by FinCEN to the DEP. If the BSA ID/DCN is unknown, zero-fill this field. If Filing Type is A Initial designation, space-fill this field Filler 42 Space-filled User 10 Use this field for any descriptive information you may require; Space-fill if no entry. 12

19 Filer Information Summary (9B) Record Required There must be one of these record types for each Filer Information (2A) Record ed on the file. This record contains counts of the number of 2B and 3A record types associated with the Filer Information (2A) Record. Position(s) Name Length Description and Remarks 1-2 Record Type 2 REQUIRED. Enter 9B. 3-9 Affiliated Bank Information (2B) Record Count Exempt Person Information (3A) Record Count 7 REQUIRED. Enter the number of Affiliated Bank Information (2B) Records for the associated Filer Information (2A) Record. 7 REQUIRED. Enter the number of Exempt Person Information (3A) Records for the associated Filer Information (2A) Record Filler 1024 Space-filled User 10 Use this field for any descriptive information you may require; Space-fill if no entry. 13

20 File Summary (9Z) Record Required There should only be one of these record types on the file and it must be the very last record ed. This record contains counts of the number of 2A, 2B, and 3A record types associated with the Transmitter (1A) Record. Position(s) Name Length Description and Remarks 1-2 Record Type 2 REQUIRED. Enter 9Z. 3-9 Filer Information (2A) Record Count Affiliated Bank Information (2B) Record Count Exempt person Information (3A) Record Count 7 REQUIRED. Enter the total number of Filer Information (2A) Records. 7 REQUIRED. Enter the total number of Affiliated Bank Information (2B) Records. 7 REQUIRED. Enter the total number of Exempt person Information (3A) Records Filler 1017 Space-filled User 10 Use this field for any descriptive information you may require; Space-fill if no entry. 14

21 Acknowledgement Record Formats The DOEP batch acknowledgement file defined below is provided in ASCII format. The acknowledgement file will contain a corresponding acknowledgement record for each record received on the batch file. Acknowledgement Transmitter (1A) Record This record is created by FinCEN as part of an acknowledgement file returned to the transmitter. This record contains identifying information and error codes pertaining to the transmitter data received by FinCEN. Position(s) Name Length Description and Remarks 1-2 Record Type 2 position 1-2 of the incoming 1A record Coverage Beginning Date 8 position of the incoming 1A record. Entered as a numeric 8-position entry in the format MMDDCCYY where MM = Month, DD = Day, CC = Century, and YY = Year Coverage Ending Date 8 position of the incoming 1A record. Entered as a numeric 8-position entry in the format MMDDCCYY where MM = Month, DD = Day, CC = Century, and YY = Year Transmitter Control Code (TCC) Batch Sequence Number (BSN) 8 position of the incoming 1A record. 3 References the batch number of the original transmission file ( , 1A record). This number is for BSA E-Filing internal use only Error Codes 30 Please see Attachment A - Error Code List for a detailed description of each error code. Error codes associated with this record begin with a T and are left-justified. Unused error code positions are zero filled User 10 Positions of the incoming 1A record Filler 21 Space-filled. 15

22 Acknowledgement Filer Information (2A) Record This record is created by FinCEN as part of an acknowledgement file returned to the transmitter. This record contains identifying information and error codes pertaining to the Filer Information (2A) Record data received by FinCEN. Position(s) Name Length Description and Remarks 1-2 Record Type 2 position 1-2 of the incoming 2A record Filer EIN 25 position of the incoming 2A record Error Codes 30 Please see Attachment A - Error Code List for a detailed description of each error code. Error codes associated with this record are three alphanumeric characters in length and are leftjustified. Unused error code positions are zero filled User 10 Positions of the incoming 2A record Filler 23 Space filled. Acknowledgement Affiliated Bank Information (2B) Record This record is created by FinCEN as part of an acknowledgement file returned to the transmitter. This record contains identifying information and error codes pertaining to the Affiliated Bank Information (2B) Record data received by FinCEN. Position(s) Name Length Description and Remarks 1-2 Record Type 2 position 1-2 of the incoming 2B record Affiliated Bank EIN 25 position of the incoming 2B record Error Codes 30 Please see Attachment A - Error Code List for a detailed description of each error code. Error codes associated with this record are three alphanumeric characters in length and are leftjustified. Unused error code positions are zero filled User 10 Positions of the incoming 2B record Filler 23 Space filled. 16

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